Intellectual Ventures I LLC v. Captal One Bank, No. 14-1506 (Fed. Cir. 2015)Annotate this Case
Intellectual Ventures owns the 137 patent, entitled “Administration of Financial Accounts,” claims methods of budgeting, particularly methods of tracking and storing information relating to a user’s purchases and expenses and presenting that information to the user based on pre-established, self-imposed spending limits. Its 382 patent, entitled “Advanced Internet Interface Providing User Display Access of Customized Webpages,” claims methods and systems for providing customized web page content to the user as a function of user-specific information and the user’s navigation history. The 587 patent, entitled “Method for Organizing Digital Images,” claims methods for scanning hard-copy images onto a computer in an organized manner. Intellectual Ventures sued, asserting infringement by Capital One. Following the district court’s claim construction of the term “machine readable instruction form” in the 587 patent, the parties stipulated to non-infringement. The district court also determined that the asserted claims of the 137 patent claimed ineligible subject matter and the asserted claims of the 382 patent claimed ineligible subject matter and were indefinite under 35 U.S.C. 112(b). The Federal Circuit affirmed, concluding that the asserted claims of the 137 and 382 patents claim unpatentable abstract ideas and that claim construction with respect to the 587 patent was correct.